Singapore Global Minimum Tax Law has been Published in the Official Gazette

On November 27, 2024, the Multinational Enterprise (Minimum Tax) Act 2024 was published in Singapore’s Official Gazette. 

The law includes an Income Inclusion Rule (IIR) (‘MTT’ in the law) and a domestic minimum tax (‘DMT’ in the law) (intended to be a Qualified Domestic Minimum Top-Up Tax (QDMTT)). This is intended to apply to fiscal years beginning on or after January 1, 2025.

Section 1 states that the law does not come into effect unless the Minister publishes an order in the Gazette, which must state the first financial year of an MNE group in relation to which the law has effect.

The law is construed as one with the Income Tax Act 1947 (“ITA”), and as such, certain provisions, such as administration, enforcement and appeals that apply under the ITA, will also apply to the DTT and MTT (with certain modifications).

The implementation of the OECD Model Rules and subsequent Administrative Guidance is split between the law and the draft regulations. The law provides the fundamental structure of the GloBE rules in Singapore with the regulations providing the more detailed GloBE income and covered taxes adjustments in order to calculate the GloBE effective tax rate (ETR).

It should be noted that Singapore has issued three sets of draft regulations:

Multinational Enterprise (Minimum Tax) Regulations 2025

Multinational Enterprise (Minimum Tax) (GloBE Safe Harbours) Regulations 2024

Multinational Enterprise (Minimum Tax) (Transition Rules) Regulations 2024

They are not, as yet, in force as subsidiary legislation will follow a different legislative process.